1.1 We are committed to safeguarding the privacy of our website visitors, Facebook, Instagram, Etsy and Twitter users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, Facebook, Instagram and Twitter users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://slscreative.com/my-account
1.5 In this policy, “we”, “us” and “our” refer to Amy Odd trading as Moving Mindset Hypnotherapy.. For more information about us, see Section 13.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
- How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website, Facebook page, Etsy Site, Instagram page, Twitter page and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data and order/contractual data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
3.5 We may process your personal data that are provided in the course of the use of our website services (“service data“). The service data may include your name, address, telephone number and email address. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website, Facebook page, Instagram page Twitter page and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you] The legal basis for this processing is namely your legitimate interests in request for service and goods information and our legitimate interests namely for the proper administration of our website, Facebook page, Instagram page, Twitter page and services and the marketing and selling of relevant goods.
3.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships and administration of our business.
3.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website and Facebook page (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.11 We may process information contained in or relating to any communication that you send to us] (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your name, address, telephone number and/or email address to our carriers Royal Mail and Hermes) as much as reasonably necessary for the purpose of delivery of your goods.
4.4 Financial transactions relating to our website and services are OR may be handled by our payment services providers, http://stripe.com, http://paypal.com and http://klarna.com . We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy https://www.paypal.com/en/webapps/mpp/ua/privacy-full and https://www.klarna.com/uk/privacy/
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country.
5.3 The hosting facilities for our website are situated in the UK and the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the UE to US Privacy Shield Framework, a copy of which you can obtain from https://www.privacyshield.gov/Program-Overview
5.4 Mailchimp and Benchmark Email are situated in the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of the USA. Transfers to the USA will be protected by appropriate safeguards, namely EU to US Privacy Shield Framework which our email service providers adhere to and you can find a copy of these at https://www.privacyshield.gov/Program-Overview
5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Personal data will be retained for a minimum period of one year and for a maximum period of seven years following consent/purchase date.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) The period of retention of personal data will be determined based on the proper administration of our website and business.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email.
- Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
- About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Cookies used by our service providers
- Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
- Our details
13.1 This website is owned and operated by Moving Mindset.
13.2 You can contact us:
(a) using our website contact form;
(b) by email, using the email address published on our website.
- Data protection officer
14.1 Our data protection officer’s contact details are: Amy Odd details as above.
Statement of Intent
I intend to ensure any data you provide is kept secure, managed respectfully and only used for the purposes for which it has been provided.
This policy will be updated periodically in line with current legislation. When you contact me via my website, phone or email I will collect your:
Any information you choose to supply regarding the purpose of your enquiry.
How is this information used?
I use this information in order to make contact with you to discuss your requirements.
I may also use this information so that I may improve my services.
During your Initial Consultation, I will ask you for your GP contact details and some basic health information: there are some conditions that are contra indicated for hypnotherapy and sometimes there are circumstance where it may be necessary to contact your GP before commencing therapy. I will inform you of this at our appointment should this appear appropriate. Rest assured your details will always be kept confidential. This confidentiality will only be broken if I feel under due care that I have the responsibility to alert the relevant authorities for safeguarding reasons. Your details are will not be shared with any third party, except in these circumstances.
You do not have to consent to the collection of information, however, if you choose not to provide it, I may not be able to work with you.
In the course of our sessions:
I will ask for your email address and phone number for the purposes of sending you a recording to listen to as part of the therapy. It may also be necessary to send emails or text messages to confirm or rearrange appointments.
I will make a note of information you provide me in order that we can plan bespoke therapy sessions and identify/produce scripts which will be used in session and/or which can be sent to you to listen to between sessions.
For the purposes of clarity, I do not receive or retain your bank details.
Under the General Data Protection Regulations which are effective from May 2018 you have the following rights:
the right to be informed (which is why we have produced this policy)
the right of access: if you wish to see your file then please make a request in writing to Amy Odd, the Data Processor. I will provide you with the information within 30 days of your request.
the right to rectification: this is your right to request changes to any information I hold that is factually inaccurate. If you believe any of the information I hold on you is incorrect then please let me know as soon as possible and I will make the relevant changes.
the right to erasure: given the nature of our work I am required to hold your details for a period of 7 years, after this your information will be securely destroyed.
the right to restrict processing: I will only use the information for the purposes that I have stated above. I uphold the common law principles of confidentiality where the duty to keep confidence is measured against the concept of ‘greater good’. If in my opinion as a therapist there is good reason to believe not to disclose would cause danger or serious harm to self, the therapist or others then your GP or other appropriate agencies may be contacted. Only information required to ensure safety of relevant parties would be disclosed. Information may have to be disclosed without consent for the prevention, detection or prosecution of a crime. The sharing of anonymous case histories with supervisors and peer support groups is not a breach of professional confidentiality.
the right to data portability: this right is more relevant to IT companies e.g. the sharing of information when moving from one utility provider to another. I will not share your information without your specific consent, other than in the situations described above.
the right to object: I will not contact you for marketing purposes unless you have given me specific consent to do so.
the right not to be subject to automated decision-making including profiling: I will not use your information for profiling purposes.
Cookies are small files which ask your permission to be placed on your computer’s hard drive so that it can analyse web traffic to my website. Through this I can see which of my website’s pages are being viewed. Most web browsers automatically accept cookies but you can modify your setting to decline them if you prefer. If you choose to do this you may find that you cannot make full use of my website.
Your details may be kept as paper records in a secured, locked cabinet to which no one has access except the data controller, or upon an encrypted device.
Visitors to my website
When someone visits my website, I use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Google Analytics to make, any attempt to find out the identities of those visiting my website.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
I use Google Analytics so that I can continually improve my service to you, You can read their privacy notice here https://policies.google.com/privacy?hl=en-US
No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.
Links to other websites
I am registered with the Information Commisioners office: ICO Registration No C1099646